2015 (11) TMI 1847

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....ue has raised three elaborate grounds in its appeal, however the crux of the issue is that the Revenue is aggrieved by the order of the Ld. CIT (A), who had allowed deduction U/s.54F to the tune of Rs. 2,47,52,000/-. 3. The brief facts of the case are that the assessee is an individual, filed his return of income on 20.07.2012 admitting his total income as Rs. 78,57,110/-. The return was taken for scrutiny and assessment U/s.143(3) of the Act was completed on 28.11.2014 wherein the Ld. Assessing Officer disallowed the claim of exemption by the assessee U/s.54F of the Act in respect of reinvestment made in purchase of house property. 4. The Ld. Assessing Officer disallowed the claim of exemption U/s.54F of the Act because according to him ....

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....e residential house at Kodaikanal. Therefore, the presumption of the AO that the appellant was in possession of two residential houses on the date of transfer is not true. The ld.AR besides filing the Settlement Deed dated 24.2.2003, has also filed the details of water supply receipts from Chennai Metropolitan Water Supply and Sewerage Board(CMWSSB), receipts of property tax to the Corporation of Chennal, electricity bill and encumbrance certificate from Registration Department wherein the name of the owner was mentioned as Shanti Thomas indicating that Mrs. Shanti Thomas was the owner of the property by the time Sholinganallur land was sold. The above details show that the appellant was not having two houses at the time of transfer of Shol....